1.18 Draft Legislation to Prevent the Abuse of Double Taxation Relief Rules
HMRC has issued draft legislation which is aimed at countering several tax avoidance schemes relating to Unauthorised Unit Trusts (‘UUTs’) and Manufactured Overseas Dividends (‘MODs’).
According to a written statement by Financial Secretary to the Treasury, Stephen Timms which was published on 21 October UUTs and MODs are being used to avoid restrictions on double tax relief and to generate ‘repayments’ of tax that the UK Exchequer has not received.
Comments are invited by 31 December 2009.
The full statement is available below at 2.08.